This policy describes (i) the types of information we may collect when the user install, subscribe to, access, and/or use the features of this Application; (ii) the types of information we may collect or that the user may provide when any advertisement or survey campaign is displayed by the Company on the Application or as part of the user’s interaction with such advertisement by the Company; (iii) how we use that information and the purposes for which we collect it; and (iv) how we disclose such information. “The Application” means and refers to the Company’s proprietary platform (application/software/website/feature or as made available in any other format) which enables end-users to explore and discover content or services through lock-screen including interesting stories, news, events, games, advertisements, etc. as they unlock their phone. The Application also enables partners to display their content (including advertising, games, promotional, entertainment or informational content) on mobile/smart devices of the end-users and sites.
This policy applies only to information we collect through the Application and in email, text, and other electronic communications sent through or in connection with the Application. It does not apply to information that we may obtain from other sources (other than Application) who provide the user’s information based on their privacy policies and the user’s interaction with their offerings. The Application may also be permitted to collect certain information about the user from the websites, applications, channels, services or landing pages (“Sites”) the user access through the Application by the provider/owner of such Sites, in which case, we will treat such information in accordance with the privacy policies of such Sites in addition to this policy, subject to the terms of the former. This policy does not apply to websites or landing pages the user may access through the Application, nor does it apply to information that the user provides to or that is collected by any third party. We encourage the user to read any such terms, conditions, policies, notices, etc. before providing information on or through them including Sites.
The Company assumes no responsibility for any third-party landing pages the user accesses or the user’s direct interaction with any third-party advertiser even if the user engages with any specific advertisement or survey campaign displayed through the Application; we recommend that the user reviews the privacy policies of such third parties that the user interacts with. Certain third parties may provide the user with ways to choose not to have the user’s information collected or used by them.
- Information collected by the Application
- Personally identifiable information:
Personally Identifiable Information means any information that may be used to identify an individual, including but not limited to the following:
(a) Information about Your personal identity inter alia as name, date of birth, gender.
(b) Your contact details such as Your address, postal code, telephone or mobile number and email id.
(c) User ID information such as Your username, email address and other security-related information used by You in relation to access and use Our Application and Content.
The aforementioned shall collectively be referred to as “Personal Information”. Personal Information will also include any personally identifiable information provided by You in any form during any interaction or communication with Us or any other users of Our Application.
When You use Our Application, We collect and store Your Personal Information in order to record, support and facilitate Your participation in the activities You select, track Your preferences, to provide You with a customized browsing experience, to notify You of any updated information and new activities and other related functions offered by the Application, keep You informed about latest Content available on the Application, special offers, and other products and services of the Application, to assist You with customer service or technical support issues, to follow up with You after Your visit. For the aforesaid purpose, We only collect such personal information that We consider relevant to understand You or Your interests including but not limited to the language in which You watch the media content, preference for sub-titles and dubbed content, and the media subscription You own etc.
3.2 Information we collect from other sources:
Automatic Information Collection and Tracking
When You access and use the Application including when You view any advertisement or interact with survey campaign displayed on the Application, it may use technology to automatically collect:
Usage Details. When You access and use the Application, We may automatically collect certain details of Your access to and use of the Platform, including interaction data, logs, and other performance data and the resources that You access and use on or through the Application, stories/videos/content You read, view, watch, interact with or otherwise access.
Device Information. We may collect information about your device and internet connection, including but not limited to, the one way hashed unique device identifier shared by OEMs, advertising identifier, GPID, GAID, device make, IP Address, display features, operating system, browser type, mobile network information. Some of these data sets may be considered to be personal information and in which case, we ensure compliance with applicable privacy laws in our collection or use of the same, to the extent applicable in such jurisdictions.
Location Information. The Application collects information about the location of Your smart device if You grant it permission to do so. You can choose whether or not to allow the Application to collect information about your device’s location by turning off the location settings on your device. If You block the use of location information, some parts of the Application may then be inaccessible or not function properly.
Usage of the device in general: The Application may collect data related to Your access of other apps/widgets, etc. used, by You, if You permit it to do so, to the extent such permission is required under privacy laws applicable in such jurisdictions.
Third-party data: This is information provided by our partners such as device manufacturers or carriers or telecom partners issuing smart devices, other application developers, data enrichment partners, etc. The information provided in those cases follows the respective privacy policies of such third-parties.
We may also use these technologies to collect information about Your activities over time and across third-party websites, apps or other online services.
In the context of advertising displayed on the Application, our customers, partners or vendors (“Ad-Third Parties”) may also disclose to us certain personal or non-personal information they have separately collected about You so that we can effectively provide our services. They do this in accordance with their specific privacy policies and subject to their own applicable legal requirements and, We will treat such information in accordance with the privacy policies of such Ad-Third Parties in addition to this policy, subject to the terms of the former. We do not use the information they provide to us for any purpose other than for providing or improving our services.
Information Collection and Tracking Technologies: The technologies we use for automatic information collection may include:
Cookies or pixels (or mobile cookies/pixels). A cookie is a small file placed on Your smart device. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on Your smart device. However, if You select this setting, You may be unable to access certain features of the Application.
Web Beacons. Pages of the Application may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or for other related statistics (for example, recording the popularity of certain application content and verifying system and server integrity).
Third-Party Information Collection: When You use the Application or its content, certain third-parties may use automatic information collection technologies to collect information about You or Your device. These third parties may include advertisers, ad networks, ad servers, attribution partners and analytics companies, Your mobile device manufacturer and/or Your mobile service provider, etc.
These third-parties may use tracking technologies to collect information about You when You use the Application. The information they collect may be associated with Your personal information or they may collect information, including personal information about Your online activities over time and across different websites, apps, and other online services. They may use this information to provide You with interest-based (behavioral) advertising or other targeted content. While We contractually require all our partners to comply with applicable privacy laws, please note that We do not control these third-parties’ tracking technologies.
Information about advertisements presented on your Application: The Company also collects some or all of the following information about an ad presented on your device: (i) the content type of the ad (what the ad is about, e.g. games, entertainment, news); (ii) the ad type (e.g. whether the ad is a text, image, or video based ad); (iii) where the ad is being served (e.g. the address of the site on which the ad appears); and (iv) certain information about post-click activity in relation to the ad including user interaction with such ad.
Information provided through surveys displayed on Your Application:
The Application may display certain marketing surveys or survey related applications to users such as yourself where You are requested to fill in a survey for services or products that You use or request provide your opinion regarding certain products or services. When You participate in our marketing or opinion-based surveys, You may voluntarily elect to provide certain data including but not limited to Your age, name, email address, phone number, gender, income range, family size, occupation, preference for brands, modes of travel, choice of food or such other consumer choices. These surveys help the brands improve their products and services offered to You. Certain surveys may also provide certain reward options for Your valuable feedback as clearly articulated in such surveys. To the extent any such information may be considered to be personal information, we ensure compliance with applicable laws in our collection or use of the same, to the extent applicable or required in such jurisdictions including certain data subject rights that you may enjoy and implement reasonable technical measures to ensure prevention of unauthorized disclosure of such personal information in our custody.
The aforementioned information herein collected by Us under Clauses 3.1 and 3.2 are collectively referred to as “Information”.
- How will Information be used:
We use the Information to understand Your needs and accordingly facilitate Our services and route You through the relevant information that meets Your need. We do not sell, rent, trade or exchange any personally identifying information of Our Users. We may provide the Information to Our affiliates and service providers under contract (such as customer care, data analytics) to support the operation of the Application and Our services. To the extent we use Your personal information to market to You, we will provide You the ability to opt-out of such uses.
4.1 Processing for User Login
We may use the Information for processing Your login for Our Application.
- Improvement of Application
We aggregate and analyze the Information that We collect and may use the same to monitor and analyze use of the Application to increase Our Application ‘s functionality, and to better tailor Our Content and design to suit Our Users’/visitors’ needs so as to provide them with a smooth, efficient, safe and customized experience while using the Application.
- Request Fulfillment & To improve Customer Service
We may also use the Information that We collect to fulfill Your requests for products, services, and information, which helps us respond to Your customer service requests and support needs, more efficiently. For example, We may use Your contact information to respond to Your customer service requests or to enable You to participate in features on the Application such as surveys, polls, and message boards. We may also use information in the aggregate to understand how Our Users as a group use the services and resources provided on Our Application and use feedback You provide to improve Our products and services.
In order to provide Our Users/visitors with free access to Our content, We display advertisements on the Application, many of which are targeted based on information about You. For example, using Information collected through cookies, web beacons, and other sources, we may use demographic data or information about Your online activities or interests to display targeted advertising that may be relevant to Your preferences. Through this process, advertisers reach Application visitors who are most interested in their products and You see advertising for products or services in which You may be interested.
In addition to the uses identified above, we may use the Information that We collect for any other purposes disclosed to You at the time We collect Your information.
- Disclosure of Information to Others
5.1 Legal Requests and/or Compliance with Applicable Laws
We cooperate with law enforcement and regulatory inquiries, as well as other third parties to enforce laws, such as intellectual property rights, fraud and other rights, to help protect You and the community. Therefore, in response to a verified request by any statutory authority including but not limited to law enforcement agency or other government officials relating to a criminal investigation or alleged illegal activity, We may (and You authorize us to) disclose, as per the applicable laws, some of Your personal information as is reasonably necessary to respond /comply with the statutory mandate including but not limited to court orders, or other legal process. We may access, use, transfer or disclose Your Personal Information to third parties such as government or law enforcement authorities or private parties, if it is legally and statutorily required to do so under any of the following conditions:
- To satisfy any applicable law, rule, regulation, governmental requests or legal process.
- To secure Our systems.
- To respond to claims that an advertisement, posting or other Content violates the rights of a third party.
- To protect the rights, property or personal safety of the Users and the public in general for any reason.
- To detect, prevent or otherwise address fraud, security or technical issues.
- To prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity.
In case of any illegal, ethical or legally actionable activity, We may use IP address or other device identifiers, to identify users, and may do so in cooperation with third parties such as internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in Our discretion. Such disclosures may be carried out without notice to You. However, We shall not sell, share or rent the Users Personal Information to any third-party or use any users e-mail id for sending any unsolicited mails.
5.2 Other Corporate Entities
5.3 Internal Service Providers
- Protection and Security Information collected by the Application
We take Our security responsibilities very seriously and take all reasonable technical and organizational measures to protect Your Information once we have received them. We use security measures consistent with current best practices to protect Our Application, email and mailing lists. These measures include technical, procedural, monitoring and tracking steps intended to safeguard data from misuse, unauthorized access or disclosure, loss, alteration or destruction.
We also have physical, electronic, and procedural safeguards that comply with the laws prevalent in India to protect personal information about You and, accordingly, We take appropriate security measures to protect against unauthorized access, alteration, disclosure or destruction of Your personal information, username, password, transaction information and data stored on Our Application in compliance with the provisions of the Information Technology Act, 2000 and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, to ensure the protection and preservation of Your privacy. In addition to the above, We, on best endeavor basis, try to limit access to personal information of Our users to only such users who We believe reasonably need to come into contact with that information to provide products or services to You. However, no data transmissions over the internet can be guaranteed to be 100 percent secure. Consequently, We cannot ensure or warrant the security of any information You transmit to Us and You understand that any information that You share is done at Your own risk.
- Retention of Personal Information
- Change in Personal Information
You are responsible for maintaining the accuracy of the Personal Information submitted at the time of login. If there are any changes in Your Personal Information details, You may correct or update the information. To do so, please log into Your account, and You will find options for editing the information You have submitted.
- 10. Data Retention Period
Company may retain the information relating to your device collected for a period of up to 36 months, unless otherwise required by law or applicable contract.
Company may retain the information it obtains about you as per the instructions of its customers or partners who provide such information or as required to fulfil our contractual obligations. In case any information is provided by you in participation of a survey, Company will only retain Your personal data for as long as necessary to fulfil the purposes it collected it for.
After the applicable retention period, the Company may retain and use such data in an aggregated format, as necessary for internal analytical purposes, to comply with its legal obligations, resolve disputes (including billing) and enforce agreements.
You expressly understand that under no circumstances, including, but not limited to, negligence, shall We be liable to You or any other person or entity for any direct, indirect, incidental, special, or consequential damages, including, but not limited to damages for loss of profits, goodwill, use, data or other intangible losses, resulting from circumstances, including but not limited to: (i) unauthorized access to or alteration of Information; (ii) any unauthorized access to or use of Our secure servers and/or any and all Information stored therein.
- Order of Prevalence:
Subject to applicable laws, the English language version of this policy will prevail over any other language version issued by Us for Your benefit.